5.9.21. Electronic Proofs of Claim (EPOC)

(1) The EPOC application is an automated system that collects proofs of claim data from the Automated Insolvency System (AIS), batches the claims by court code designation, and transmits the claim data to the individual U.S. Bankruptcy Courts. A proof of claim is a statement filed with the bankruptcy court listing debts owed by the debtor to a particular creditor.

(2) IRM 5.9, Bankruptcy and Other Insolvencies, contains the IRS’s position, procedures, information, instructions, guidance, and references concerning bankruptcy cases, stockbroker insolvencies, receiverships, assignments for the benefit of creditors, corporate dissolutions, and bulk sales.

(1) The EPOC program operates within the guidelines of the Bankruptcy Code (11 USC), the Bankruptcy Reform Act of 1994 (BRA 94), and the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA).

(1) IRM 5.9, Bankruptcy and Other Insolvencies, provides a list of titles and responsibilities with an explanation of their roles and authority.

(2) Field bankruptcy specialists are responsible for ensuring that proofs of claim for cases assigned to them are submitted timely for EPOC. EPOC Operators are responsible for running the EPOC application daily. CIO management will ensure that daily transmissions have been completed and that transmission errors are resolved. AIS system analysts will monitor the daily transmissions and work to resolve system issues.

(1) Three AIS Reports: Denied EPOC Claims, EPOC Submission Status, and EPOC Status, are used to support program objectives. These reports are described in detail in IRM 5.9.21.2.4, EPOC Reports.

(2) CIO managers will review the Denied EPOC Claims report, EPOC Submission Status report, and EPOC Status report to identify errors and potential program weaknesses.

(3) The Collection Policy, Insolvency program analyst will periodically run the EPOC Submission Status report to ensure that all court’s claims have been processed.

(1) Managers are required to follow program management procedures and controls addressed in IRM 1.4.51.5.2, Reviews (Overview), IRM 1.4.51.15, Controls, andIRM 1.4.51.16, Quality.

(2) Operational and Program reviews are conducted on a yearly basis. See IRM 1.4.51.17.2, Operational Review, and IRM 1.4.51.17.5, Program Reviews, for more information.

(1) The following chart contains acronyms used through this IRM:

(1) Document 13219, Automated Insolvency System (AIS) User Guide.

(2) Procedural guidance on insolvencies can be found throughout IRM 5.9, Bankruptcy and Other Insolvencies.

(3) Document 13163, Automated Proof of Claim (APOC) & APOC Amends User Guide

(1) Electronic Filing Required. Some courts require or request electronic filing of proofs of claim through the courts’ Case Management/Electronic Claim Filing (CM/ECF) websites. Access to the CM/ECF is coordinated locally with the court. Specialty Collection Insolvency group managers are required to submit LOGIN applications to each court for CM/ECF privileges. The courts provide website documentation and training. The AIS court screen provides an indicator for courts requiring electronic filing of claims.

(2) EPOC Interface. IRS regulations require additional security measures with EPOC use. IRS claims can only be submitted to CM/ECF websites by a secure EPOC interface. EPOC transmits the AIS claim data to the court websites. EPOC also supplies the PDF claim document required by the court websites.

(3) Access to CM/ECF Sites. The CIO is the only office performing the actual EPOC transmissions. Only CIO users need access to the EPOC interface. An EPOC button found in the AIS main menu is used to open and operate the interface. This EPOC button will only work for employees with the CIO Processing Role. A BEARS Add User request for the CIO Processing Role is required by the IRS to request EPOC access.

(1) The EPOC Process. From the Proofs of Claim menu, the user selects the appropriate claim and then selects the button to Submit Claim for EPOC. The creditor number assigned for each case must be added to AIS prior to submitting the claim for EPOC transmission. The creditor number is automatically downloaded for cases received through the Electronic Notice System (ENS). However, for cases added to AIS manually, the creditor number must also be manually added. Creditor numbers are secured from PACER and CM/ECF. Claims are held in a queue until they are transmitted to a court’s CM/ECF website through the AIS - EPOC interface. The following table illustrates the steps in sending a claim via EPOC.

1. When a claim is added to AIS, either by the APOC system or manually, the Proof Prepared date is blank, and the Proof Required field on the Taxpayer Screen should be "Yes." The case will be on the Bar Date report, but not on the POC F/U Report.

   Note: All claims should be assigned to the appropriate responsible Field Insolvency specialist at the time that the claim (original or amended) is submitted to EPOC. This will ensure that the Field Insolvency specialist’s contact information is displayed on the official Proof of Claim.

2. To file claims to an EPOC court, use the Submit for EPOC - Original button on the Proof of Claim screen or by selecting the Process APOC and EPOC button on the APOC Case Detail screen. When the claim is picked up for overnight processing, the status changes to Currently Being Processed and the Proof Prepared date is filled in. The Proof Required field on the Taxpayer Screen is not changed. The case will be on the Proof of Claim Follow-up report. The case will be on the EPOC Status report.

3. After EPOC files the claim, AIS is updated with the information from the court and the EPOC status is updated. If the claim is successfully filed, the Proof Acknowledgement date is filled in and the Proof Required field on the Taxpayer Screen is changed to "Filed." The case will not be on a Bar Date or POC F/U report. If the claim is rejected, the Proof Acknowledgement date is NOT filled in, the Proof Required field on the Taxpayer Screen is changed to "Rejected." The case remains on the Bar Date report. See IRM 5.9.21.2.4.

(2) Amending a Claim. A claim number is systemically input to the "claim number" field on the proof of claim screen. EPOC adds the court's claim number at the same time it inputs the court's acknowledgment date.

1. When a claim is amended, the bankruptcy specialist must ensure the court's original claim number is shown on the AIS Proof of Claim screen prior to submitting the amended claim to EPOC.

2. If a claim appears on the claim registry with a zero claim number, the caseworker must contact the court to have it assigned a valid claim number.

3. Amended claims without an original claim number and/or an amended claim number on AIS will be rejected by AIS. An error message will appear when the user attempts to submit the claim for EPOC instructing the user to enter the appropriate claim numbers.

4. The caseworker will select the Submit to EPOC - Amended button to submit the amended claim for EPOC. AIS will enter the appropriate amended number and prepared date. Amended claims follow the same processing steps as listed above.

(3) Withdrawing a Claim. To withdraw a claim filed through EPOC, it must be amended to $0.00 and submitted by clicking on the Submit to EPOC - Amended button on the Proof of Claim Screen. If a court does not accept this method of withdrawing a claim, the specialist can send a letter instructing the court to remove a specific claim from the claims register. For those courts, caseworkers can generate Letter 3931, Request to Withdraw Administrative Proof Claim, on AIS for mailing to the court.

(1) Using the EPOC Interface. To access the EPOC interface, the designated EPOC operator selects the EPOC button located in the AIS main menu.

(2) EPOC Message of the Day (MOTD).

1. When an authorized EPOC operator selects the EPOC button, the EPOC screen will appear displaying the EPOC Message of the Day (MOTD).

2. The following navigation buttons will be visible: Claim Filing and Claim Filing Status.

(3) Claim Filing. Select the Claim Filing button from the Navigation menu. The Claim Filing screen allows the user to display the pending Proofs of Claim for a specific court jurisdiction.

1. The EPOC operator next selects their assigned court to process by selecting the Jurisdiction from the drop down menu box. For example, to load claims to transmit to the Arizona court, the user must scroll through the list of courts and select "AZ."

Note: If a court code is not listed in the Jurisdiction drop down menu box, then no claims were submitted for processing to that court for that day. If an EPOC operator notices that no claims have appeared for a specific court for more than three days, then they should notify their manager. There may be an issue with that specific court that should be researched by the Collection Policy Analyst. The EPOC operator’s manager will contact the Collection Policy Analyst.

2. The claims to be processed for the specified court will appear in a column format showing important claim data, such as AIS case number, court, form, creditor number, status, date created, claim number, amended number, and the various claim amount data. None of the claims will be selected for processing as a default. Claims in this screen will be in the "P" (Process). These claims need to be submitted for processing. The claim may also be in "U" (Unknown) status.

   Note: Unknown errors occur when the creditor page elements do not appear to load after a maximum of 20 seconds within the EPOC claim data transmission process. EPOC operators must submit these claims again to the court. They will usually process the second time they are transmitted.

3. For quick submission of all claims to the court – the EPOC operator should select the Select All and Submit button. The EPOC operator can also submit individual claims by selecting them one at a time and then selecting the Submit Selected Claims button.

Note: If a claim is not selected for processing, then the next time that screen is refreshed, that claim will reappear. If the case is removed from the AIS side of the application, then it will no longer show on the list.

4. When claims are submitted for EPOC transmission, the Claim Filing screen will display the total number of claims that were submitted.

5. EPOC will take the following actions, which the EPOC operator will not see:

EPOC Actions
-Determine whether the court uses the single claim upload or multi-claim zip upload process.
-Log into the court’s CM/ECF website.
-Provide the creditor number and claim amount data for each claim submitted.
-Attach the PDF proofs of claim documents.
-Capture the acknowledgement data and update the AIS POC and History screens.

Note: If the court website is unreachable, or the EPOC login/password is invalid, a systemic e-mail will be sent to the Information Technology (IT) Developers and Collection Policy, Insolvency Program Analysts.

(4) Claim Filing Status. To review the status of claims submitted that day, the EPOC operator can review the Claim Filing Status screen. The EPOC operator must select the Claim Filing Status button in the top navigation menu while in the Claim Filing or MOTD screens.

1. The EPOC operator must select the court initials from the Jurisdiction drop down menu box.

2. The Claim Filing Status screen will display all claims for that court for that day listing the court case number, court, form, creditor number, date created, claim number, amended number, status, and a message.

3. The Status Codes include:

Status	Definition
P	Process (Claims received from AIS that still need to be “processed” by EPOC - the EPOC operator still needs to submit these to the court).
S	Submitted (Claims that have been submitted to the court by EPOC and are waiting on the court’s response).
A	Accepted (by the court).
D	Denied (by the court - the message column will explain why it’s denied - these claims will appear on the Denied EPOC Claims and EPOC Status reports).
U	Unknown (will appear when there is an internet transmission interruption - these claims will appear on the EPOC Submission Status report. They also will appear in the Claim Filing screen). Note: They must be submitted again to the court either the same day or the following day.

(5) Exiting EPOC. When an EPOC operator has completed submitting the claims for each assigned court jurisdiction, they must select any other menu button to leave the EPOC screen or they can select the Logout button to completely close AIS.

(1) Business Objects Environment (BOE).Business Objects for AIS contains three important EPOC Reports that must be reviewed and worked to ensure that all claims are correctly transmitted, accepted, and acknowledged. The Denied EPOC Claims report, EPOC Submission Status report, and the EPOC Status report will identify rejected claims and claims that still need processing.

(2) Identifying Rejected Claims. The court's rejection of an original claim is indicated in the "EPOC Status" field of the Proof Screen with the annotation "Rejected by Court," and the Filed indicator in the "Proof Required" field on the Taxpayer Screen changes to Rejected. Rejected claims also appear on the Bar Date report and are systemically annotated in the AIS case history. When the claim is resubmitted and subsequently accepted, the R in the AIS Proof Required field reverts to Filed for original claims, and the EPOC Status field shows "Accepted by Court." If for some reason the Rejected indicator does not revert to show Filed systemically, the case must be referred to a manager to input the Filed indicator manually.

(3) Systemic Histories. EPOC creates systemic AIS histories for rejected claims:

1. Incorrect Creditor Number, Invalid Creditor Number, or Creditor Number Not Found. This indicates the claim is not filed. The EPOC operator must research the creditor number on CM/ECF using the generic login and password. Then the EPOC operator must update AIS with the correct creditor number and resubmit the claim by clicking the "Submit to EPOC - Original or Submit to EPOC - Amended" buttons on the AIS Proof of Claim screen.

2. Incorrect Case Number. This indicates the claim is not filed. The EPOC operator must verify the docket number and court key, update the docket number and/or court key on AIS if needed, and resubmit the claim by selecting the "Submit to EPOC - Original or Submit to EPOC - Amended" buttons on the AIS Proof of Claim screen.

3. Invalid Amendment Number. This indicates the amended claim may not be filed. The EPOC operator should check PACER to determine if the claim was accepted. If not, the amended claim number must be updated and then should be resubmitted by clicking the "Submit to EPOC - Amended" button on the AIS Proof of Claim screen.

4. No Confirmation Stamp. This rejection message is triggered by systemic interruptions in the court's website. The EPOC operator must check PACER to determine if the claim was accepted. If it was accepted, the EPOC operator must update the acknowledgement date and document the history screen. If the claim was not accepted, the EPOC operator must resubmit the claim by clicking the "Submit to EPOC - Original or Submit to EPOC - Amended" buttons on the AIS Proof of Claim screen.

5. Failed Pre-Validation. This error occurs with courts running the zip upload process. The case that errors out may have an issue with its docket number or docket format, the creditor number, the court code, the judge’s initials, the chapter, or the address. The EPOC operator must research the case on PACER, make any necessary changes to AIS, and resubmit the claim by clicking the "Submit to EPOC - Original or Submit to EPOC - Amended" buttons on the AIS Proof of Claim screen.

(4) Denied EPOC Claims Report. The Denied EPOC Claims report is generated using Business Objects for AIS. The Denied EPOC Claims report will list Rejected and Unacknowledged claims on open AIS cases. A Denied EPOC Claims report must be generated daily for each EPOC court by following the steps below.

(5) EPOC Submission Status Report. The EPOC Submission Status Report is generated using Business Objects for AIS. This report focuses on the transmission status of claims within EPOC, not AIS. It can list all claims for a specified date range within a specified category, such as Accepted, Rejected, Submission Cancelled, Submission Re-queued, Selected for Court Upload, Currently Being Processed, and Unknown. Analysts and managers will use this report to review the daily EPOC transmissions by following the steps below.

(6) EPOC Status Report. The EPOC Status report is generated using Business Objects for AIS. The EPOC Status report will list all AIS claims with an open EPOC status: Rejected, Processing, or Submitted. This report can also list all Accepted cases within a specified date range. Analysts and managers will use this report to focus on specific EPOC data when reviewing the EPOC inventory. The report can be generated using the steps below.

1. Access Business Objects for AIS and locate the report in the Public Folders.

2. Select the "EPOC Status" report.

3. Select the appropriate Beginning and Ending dates in the menu-prompt box.

4. Run the report for all courts (Leave the courts box blank), or for a specific court. For example, enter TXN% for all Texas North courts.

5. The Org1, Org2, Group and SEID fields should remain blank.

6. AIS will generate a spreadsheet listing of claims.

7. Claims listed as Rejected or Currently Processing will also be found on the Denied EPOC Claims report.

(1) If CIO receives a call from a Field Insolvency specialist, advisor, or manager stating that a claim should not be transmitted to the court, the CIO EPOC Operator Manager/Lead/System Analyst should take the following steps:

1. Make sure the claim is not selected when transmitting the rest of the claims to the court that day.

2. Go to the AIS Proof of Claim screen and select the Cancel EPOC button. This will change the EPOC Status from "Currently being Processed" to "Not Submitted" and will add a history item.

3. This will remove the claim from the EPOC Claim Filing queue.

4. Field Insolvency Specialists can also cancel their own claims. On the AIS Proof of Claim screen, if the EPOC status is "Submitted for Processing", then they must select the Cancel Submit to EPOC button. If the EPOC status is "Currently Processing", then they must select the Cancel EPOC button.